The Basel ii
Accord
From the Basel ii Compliance Professionals Association (BCPA)
the largest association of Basel ii Professionals in the
world
2. Risk
components
359. In general, the measure of an equity
exposure on which capital requirements is based is
the value presented in the financial statements, which
depending on national accounting and regulatory
practices may include unrealised revaluation gains.
Thus, for example, equity exposure measures will
be:
• For investments held at fair value with changes
in value flowing directly through income and into
regulatory capital, exposure is equal to the fair value
presented in the balance sheet.
• For investments
held at fair value with changes in value not flowing
through income but into a tax-adjusted separate
component of equity, exposure is equal to the
fair value presented in the balance sheet.
• For
investments held at cost or at the lower of cost or
market, exposure is equal to the cost or market value
presented in the balance sheet. *
*
This does not affect the existing
allowance of 45% of unrealised gains to Tier 2
capital in the 1988 Accord
360. Holdings in
funds containing both equity investments and other
non-equity types of investments can be either
treated, in a consistent manner, as a single investment
based on the majority of the fund’s
holdings or, where possible, as separate and distinct
investments in the fund’s component holdings based on
a look-through approach.
361. Where only the
investment mandate of the fund is known, the fund can
still be treated as a single investment.
For this
purpose, it is assumed that the fund first invests,
to the maximum extent allowed under its mandate, in
the asset classes attracting the highest capital
requirement, and then continues making investments in
descending order until the maximum total investment
level is reached.
The same approach can also be used for
the look-through approach, but only where the bank
has rated all the potential constituents of such a
fund.
F. Rules for Purchased Receivables
362.
Section F presents the method of calculating the UL
capital requirements for purchased receivables.
For
such assets, there are IRB capital charges for both
default risk and dilution risk. Section III.F.1
discusses the calculation of risk-weighted assets for
default risk.
The calculation of risk-weighted assets
for dilution risk is provided in Section III.F.2.
The method of calculating expected losses, and for
determining the difference between that measure and
provisions, is described in Section III.G.
1.
Risk-weighted assets for default risk
363. For
receivables belonging unambiguously to one asset class,
the IRB risk weight for default risk is based on the
risk-weight function applicable to that particular
exposure type, as long as the bank can meet the
qualification standards for this particular risk-weight
function.
For example, if banks cannot comply with
the standards for qualifying revolving
retail exposures (defined in paragraph 234), they
should use the risk-weight function for other
retail exposures.
For hybrid pools containing
mixtures of exposure types, if the purchasing
bank cannot separate the exposures by type, the
risk-weight function producing the highest
capital requirements for the exposure types in the
receivable pool applies.
(i) Purchased retail
receivables
364. For purchased retail receivables, a
bank must meet the risk quantification standards for
retail exposures but can utilise external and internal
reference data to estimate the PDs and LGDs.
The
estimates for PD and LGD (or EL) must be calculated for
the receivables on a stand-alone basis; that is,
without regard to any assumption of recourse or
guarantees from the seller or other parties.
(ii)
Purchased corporate receivables
365. For purchased
corporate receivables the purchasing bank is expected to
apply the existing IRB risk quantification standards
for the bottom-up approach.
However, for
eligible purchased corporate receivables, and subject
to supervisory permission, a bank may employ the
following top-down procedure for calculating IRB risk
weights for default risk:
• The purchasing bank will
estimate the pool’s one-year EL for default risk,
expressed in percentage of the exposure amount (i.e.
the total EAD amount to the bank by all obligors in
the receivables pool).
The estimated EL must be
calculated for the receivables on a stand-alone
basis; that is, without regard to any assumption
of recourse or guarantees from the seller or
other parties.
The treatment of recourse
or guarantees covering default risk (and/or dilution
risk) is discussed separately below.
• Given the EL
estimate for the pool’s default losses, the risk weight
for default risk is determined by the risk-weight
function for corporate exposures. *
As
described below, the precise calculation of risk
weights for default risk depends on the
bank’s ability to decompose EL into its PD and LGD
components in a reliable manner.
Banks can utilise
external and internal data to estimate PDs and LGDs.
However, the advanced approach will not be available
for banks that use the foundation approach for
corporate exposures.
*
The
firm-size adjustment for SME, as defined in paragraph
273, will be the weighted average by individual exposure
of the pool of purchased corporate receivables. If the
bank does not have the information to calculate the
average size of the pool, the firm-size adjustment will
not apply.
Foundation IRB treatment
366.
If the purchasing bank is unable to decompose EL into
its PD and LGD components in a reliable manner, the
risk weight is determined from the corporate risk-weight
function using the following specifications: if the
bank can demonstrate that the exposures
are exclusively senior claims to corporate borrowers,
an LGD of 45% can be used.
PD will be calculated by
dividing the EL using this LGD. EAD will be calculated
as the outstanding amount minus the capital charge
for dilution prior to credit risk mitigation
(KDilution).
Otherwise, PD is the bank’s estimate of
EL; LGD will be 100%; and EAD is the amount
outstanding minus KDilution. EAD for a revolving
purchase facility is the sum of the current amount
of receivables purchased plus 75% of any undrawn
purchase commitments minus KDilution.
If
the purchasing bank is able to estimate PD in a
reliable manner, the risk weight is determined from
the corporate risk-weight functions according to the
specifications for LGD, M and the treatment of
guarantees under the foundation approach as given in
paragraphs 287 to 296, 299, 300 to 305, and
318.
Advanced IRB treatment
367. If the purchasing
bank can estimate either the pool’s default-weighted
average loss rates given default (as defined in
paragraph 468) or average PD in a reliable manner,
the bank may estimate the other parameter based on an
estimate of the expected long-run loss rate.
The bank
may
(i) use an appropriate PD estimate to infer the
long-run default-weighted average loss rate given
default, or
(ii) use a long-run default-weighted average
loss rate given default to infer the appropriate PD.
In either case, it is important to recognise that
the LGD used for the IRB capital calculation for
purchased receivables cannot be less than
the long-run default-weighted average loss rate given
default and must be consistent with the concepts
defined in paragraph 468.
The risk weight for the
purchased receivables will be determined using the
bank’s estimated PD and LGD as inputs to the corporate
risk-weight function.
Similar to the foundation IRB
treatment, EAD will be the amount outstanding
minus KDilution. EAD for a revolving purchase
facility will be the sum of the current amount
of receivables purchased plus 75%
of any undrawn
purchase commitments minus KDilution (thus, banks
using the advanced IRB approach will not be permitted to
use their internal EAD estimates for undrawn purchase
commitments).
368. For drawn amounts, M will equal
the pool’s exposure-weighted average
effective maturity (as defined in paragraphs 320 to
324). This same value of M will also be used
for undrawn amounts under a committed purchase
facility provided the facility contains
effective covenants, early amortisation triggers, or
other features that protect the purchasing bank against a significant deterioration in
the quality of the future receivables it is required
to purchase over the facility’s term.
Absent such
effective protections, the M for undrawn amounts will
be calculated as the sum of
(a) the longest-dated
potential receivable under the purchase agreement and
(b) the remaining maturity of
the purchase facility.
2. Risk-weighted assets for dilution
risk
369. Dilution refers to the possibility that the
receivable amount is reduced through cash or non-cash
credits to the receivable’s obligor. *
For both
corporate and retail receivables, unless the bank can
demonstrate to its supervisor that the dilution risk for
the purchasing bank is immaterial, the treatment of
dilution risk must be the following: at the level of
either the pool as a whole (top-down approach) or the
individual receivables making up the pool (bottom-up
approach), the purchasing bank will estimate the
one-year EL for dilution risk, also expressed in
percentage of the receivables amount.
Banks can utilise
external and internal data to estimate EL.
As with
the treatments of default risk, this estimate must
be computed on a stand-alone basis; that is, under
the assumption of no recourse or other support from
the seller or third-party guarantors.
For the purpose of
calculating risk weights for dilution risk, the
corporate risk-weight function must be used with the
following settings: the PD must be set equal to the
estimated EL, and the LGD must be set at 100%.
An appropriate maturity treatment applies when
determining the capital requirement for
dilution risk.
If a bank can demonstrate that the
dilution risk is appropriately monitored and
managed to be resolved within one year, the
supervisor may allow the bank to apply a
one-year maturity.
*
Examples include offsets or allowances arising from
returns of goods sold, disputes regarding product
quality, possible debts of the borrower to a receivables
obligor, and any payment or promotional discounts
offered by the borrower (e.g. a credit for cash payments
within 30 days).
370. This treatment will be
applied regardless of whether the underlying receivables
are corporate or retail exposures, and regardless of
whether the risk weights for default risk
are computed using the standard IRB treatments or,
for corporate receivables, the top-down treatment
described above.
3. Treatment of purchase price
discounts for receivables
371. In many cases, the
purchase price of receivables will reflect a discount
(not to be confused with the discount concept defined
in paragraphs 308 and 334) that provides first loss
protection for default losses, dilution losses or both
(see paragraph 629).
To the extent a portion of such
a purchase price discount will be refunded to the
seller, this refundable amount may be treated as
first loss protection under the IRB securitisation
framework.
Non refundable purchase price discounts for
receivables do not affect either the
EL-provision calculation in Section III.G or the
calculation of risk-weighted assets.
372. When
collateral or partial guarantees obtained on receivables
provide first loss protection (collectively referred
to as mitigants in this paragraph), and these mitigants
cover default losses, dilution losses, or both, they
may also be treated as first loss protection
under the IRB securitisation framework (see paragraph
629).
When the same mitigant covers both default and
dilution risk, banks using the Supervisory Formula that
are able to calculate an exposure-weighted LGD must
do so as defined in paragraph 634.
4. Recognition
of credit risk mitigants
373. Credit risk mitigants
will be recognised generally using the same type of
framework as set forth in paragraphs 300 to 307.85 In
particular, a guarantee provided by the seller or
a third party will be treated using the existing IRB
rules for guarantees, regardless of whether the
guarantee covers default risk, dilution risk, or
both.
• If the guarantee covers both the pool’s
default risk and dilution risk, the bank
will substitute the risk weight for an exposure to
the guarantor in place of the pool’s total risk
weight for default and dilution risk.
• If the
guarantee covers only default risk or dilution risk, but
not both, the bank will substitute the risk weight
for an exposure to the guarantor in place of the pool’s
risk weight for the corresponding risk component
(default or dilution).
The capital requirement for
the other component will then be added.
• If a
guarantee covers only a portion of the default and/or
dilution risk, the uncovered portion of the default
and/or dilution risk will be treated as per the existing
CRM rules for proportional or tranched coverage (i.e.
the risk weights of the uncovered risk components
will be added to the risk weights of the covered risk
components).
373 (i). If protection against dilution
risk has been purchased, and the conditions
of paragraphs 307 (i) and 307 (ii) are met, the
double default framework may be used for
the calculation of the risk-weighted asset amount for
dilution risk. *
In this case, paragraphs 284 (i) to
284 (iii) apply with PDo being equal to the estimated
EL, LGDg being equal to 100 percent, and effective
maturity being set according to paragraph 369.
*
At national supervisory discretion, banks may recognise
guarantors that are internally rated and associated with
a PD equivalent to less than A- under the foundation IRB
approach for purposes of determining capital
requirements for dilution risk.
G.
Treatment of Expected Losses and Recognition of
Provisions
374. Section III.G discusses the method by
which the difference between provisions
(e.g. specific provisions, portfolio-specific general
provisions such as country risk provisions or general
provisions) and expected losses may be included in or
must be deducted from regulatory capital, as outlined
in paragraph 43.
1. Calculation of expected
losses
375. A bank must sum the EL amount (defined as
EL multiplied by EAD) associated with its exposures
(excluding the EL amount associated with equity
exposures under the PD/LGD approach and
securitisation exposures) to obtain a total EL amount.
While the EL amount associated with equity exposures
subject to the PD/LGD approach is excluded from the
total EL amount, paragraphs 376 and 386 apply to such
exposures.
The treatment of EL for securitisation
exposures is described in paragraph 563.
(i) Expected
loss for exposures other than SL subject to the
supervisory slotting criteria
376. Banks must
calculate an EL as PD x LGD for corporate, sovereign,
bank, and retail exposures both not in default and
not treated as hedged exposures under the double
default treatment.
For corporate, sovereign, bank,
and retail exposures that are in default, banks must
use their best estimate of expected loss as defined in
paragraph 471 and banks on the foundation approach
must use the supervisory LGD.
For SL exposures subject
to the supervisory slotting criteria EL is
calculated as described in paragraphs 377 and 378.
For equity exposures subject to the PD/LGD approach,
the EL is calculated as PD x LGD unless paragraphs
351 to 354 apply. Securitisation exposures do not
contribute to the EL amount, as set out in paragraph
563.
For all other exposures, including hedged exposures
under the double default treatment, the EL is
zero.
(ii) Expected loss for SL exposures subject to
the supervisory slotting criteria
377. For SL
exposures subject to the supervisory slotting criteria,
the EL amount is determined by multiplying 8% by the
risk-weighted assets produced from the appropriate
risk weights, as specified below, multiplied by
EAD.
Supervisory categories and EL risk weights for
other SL exposures
378. The risk weights for SL,
other than HVCRE, are as follows:

Where, at national discretion, supervisors allow
banks to assign preferential risk weights to other SL
exposures falling into the “strong” and “good”
supervisory categories as outlined in paragraph 277,
the corresponding EL risk weight is 0% for “strong”
exposures, and 5% for “good”
exposures.
Supervisory categories and EL risk weights
for HVCRE
379. The risk weights for HVCRE are as
follows:

Even where, at national discretion,
supervisors allow banks to assign preferential
risk weights to HVCRE exposures falling into the
“strong” and “good” supervisory categories
as outlined in paragraph 282, the corresponding EL
risk weight will remain at 5% for both “strong” and
“good” exposures.
2. Calculation of provisions
(i)
Exposures subject to IRB approach
380. Total eligible
provisions are defined as the sum of all provisions
(e.g. specific provisions, partial write-offs,
portfolio-specific general provisions such as country
risk provisions or general provisions) that are
attributed to exposures treated under the
IRB approach.
In addition, total eligible provisions
may include any discounts on defaulted
assets.
Specific provisions set aside against equity
and securitisation exposures must not be included in
total eligible provisions.
(ii) Portion of exposures
subject to the standardised approach to credit
risk
381. Banks using the standardised approach for a
portion of their credit risk exposures, either on a
transitional basis (as defined in paragraphs 257 and
258), or on a permanent basis if the exposures
subject to the standardised approach are immaterial
(paragraph 259), must determine the portion of
general provisions attributed to the standardised or
IRB treatment of provisions (see paragraph 42)
according to the methods outlined in paragraphs 382
and 383.
382. Banks should generally attribute total
general provisions on a pro rata basis according to
the proportion of credit risk-weighted assets subject to
the standardised and IRB approaches.
However, when
one approach to determining credit risk-weighted assets
(i.e. standardised or IRB approach) is used
exclusively within an entity, general
provisions booked within the entity using the
standardised approach may be attributed to
the standardised treatment.
Similarly, general
provisions booked within entities using the IRB approach may be attributed to the total eligible
provisions as defined in paragraph 380.
383. At
national supervisory discretion, banks using both the
standardised and IRB approaches may rely on their
internal methods for allocating general provisions
for recognition in capital under either the
standardised or IRB approach, subject to the
following conditions.
Where the internal allocation
method is made available, the national
supervisor will establish the standards surrounding
their use. Banks will need to obtain prior
approval from their supervisors to use an internal
allocation method for this purpose.
3. Treatment of
EL and provisions
384. As specified in paragraph 43,
banks using the IRB approach must compare the
total amount of total eligible provisions (as defined
in paragraph 380) with the total EL amount
as calculated within the IRB approach (as defined in
paragraph 375).
In addition, paragraph 42 outlines
the treatment for that portion of a bank that is subject
to the standardised approach to credit risk when the
bank uses both the standardised and IRB
approaches.
385. Where the calculated EL amount is
lower than the provisions of the bank,
its supervisors must consider whether the EL fully
reflects the conditions in the market in which it
operates before allowing the difference to be included
in Tier 2 capital.
If specific provisions exceed the
EL amount on defaulted assets this assessment also needs
to be made before using the difference to offset the
EL amount on non-defaulted assets.
386. The EL amount
for equity exposures under the PD/LGD approach is
deducted 50% from Tier 1 and 50% from Tier 2.
Provisions or write-offs for equity exposures under
the PD/LGD approach will not be used in the
EL-provision calculation.
The treatment of EL
and provisions related to securitisation exposures is
outlined in paragraph 563.
H. Minimum Requirements
for IRB Approach
387. Section III.H presents the
minimum requirements for entry and on-going use of
the IRB approach. The minimum requirements are set
out in 12 separate sections concerning:
(a)
composition of minimum requirements,
(b) compliance with
minimum requirements,
(c) rating system design,
(d)
risk rating system operations,
(e) corporate governance
and oversight,
(f) use of internal ratings,
(g) risk
quantification,
(h) validation of internal
estimates,
(i) supervisory LGD and EAD estimates,
(j)
requirements for recognition of leasing,
(k) calculation of capital charges for equity
exposures, and
(l) disclosure requirements.
It may
be helpful to note that the minimum requirements cut
across asset classes.
Therefore, more than one asset
class may be discussed within the context of a given
minimum requirement.
1. Composition of minimum
requirements
388. To be eligible for the IRB approach
a bank must demonstrate to its supervisor that
it meets certain minimum requirements at the outset
and on an ongoing basis.
Many of these requirements
are in the form of objectives that a qualifying bank’s
risk rating systems must fulfil.
The focus is on
banks’ abilities to rank order and quantify risk in a
consistent, reliable and valid fashion.
389. The
overarching principle behind these requirements is that
rating and risk estimation systems and processes
provide for a meaningful assessment of borrower
and transaction characteristics; a meaningful
differentiation of risk; and reasonably accurate
and consistent quantitative estimates of risk.
Furthermore, the systems and processes must
be consistent with internal use of these estimates.
The Committee recognises that differences in markets,
rating methodologies, banking products, and practices
require banks and supervisors to customise their
operational procedures.
It is not the Committee’s
intention to dictate the form or operational detail
of banks’ risk management policies and practices.
Each supervisor will develop detailed review
procedures to ensure that banks’ systems and controls
are adequate to serve as the basis for the IRB
approach.
390. The minimum requirements set out in
this document apply to all asset classes unless noted
otherwise.
The standards related to the process of
assigning exposures to borrower or facility grades
(and the related oversight, validation, etc.) apply
equally to the process of assigning retail exposures
to pools of homogenous exposures, unless
noted otherwise.
391. The minimum requirements set
out in this document apply to both foundation
and advanced approaches unless noted otherwise.
Generally, all IRB banks must produce their own
estimates of PD * and must adhere to the overall
requirements for rating system design, operations,
controls, and corporate governance, as well as the
requisite requirements for estimation and validation
of PD measures.
Banks wishing to use their own estimates
of LGD and EAD must also meet the incremental minimum
requirements for these risk factors included in
paragraphs 468 to 489.
*
Banks are not required to produce their own estimates of
PD for certain equity exposures and certain exposures
that fall within the SL sub-class.
2. Compliance with minimum
requirements
392. To be eligible for an IRB approach,
a bank must demonstrate to its supervisor that
it meets the IRB requirements in this document, at
the outset and on an ongoing basis.
Banks’ overall
credit risk management practices must also be consistent
with the evolving sound practice guidelines issued by
the Committee and national supervisors.
393. There
may be circumstances when a bank is not in complete
compliance with all the minimum requirements.
Where
this is the case, the bank must produce a plan for a
timely return to compliance, and seek approval from
its supervisor, or the bank must demonstrate that the
effect of such non-compliance is immaterial in terms of
the risk posed to the institution.
Failure to produce
an acceptable plan or satisfactorily implement the plan
or to demonstrate immateriality will lead supervisors
to reconsider the bank’s eligibility for the
IRB approach.
Furthermore, for the duration of any
non-compliance, supervisors will consider the need
for the bank to hold additional capital under Pillar 2
or take other appropriate supervisory action.
3. Rating
system design
394. The term “rating system” comprises
all of the methods, processes, controls, and data
collection and IT systems that support the assessment of
credit risk, the assignment of internal risk ratings,
and the quantification of default and loss
estimates.
395. Within each asset class, a bank may
utilise multiple rating methodologies/systems.
For
example, a bank may have customised rating systems for
specific industries or market segments (e.g. middle
market, and large corporate).
If a bank chooses to use
multiple systems, the rationale for assigning a
borrower to a rating system must be documented
and applied in a manner that best reflects the level
of risk of the borrower.
Banks must not allocate
borrowers across rating systems inappropriately to
minimise regulatory capital requirements (i.e.
cherry-picking by choice of rating system).
Banks must
demonstrate that each system used for IRB purposes is
in compliance with the minimum requirements at
the outset and on an ongoing basis.
(i) Rating
dimensions
Standards for corporate, sovereign, and
bank exposures
396. A qualifying IRB rating system
must have two separate and distinct dimensions:
(i)
the risk of borrower default, and
(ii)
transaction-specific factors.
397. The first
dimension must be oriented to the risk of borrower
default.
Separate exposures to the same borrower must
be assigned to the same borrower grade,
irrespective of any differences in the nature of each
specific transaction.
There are two exceptions to
this.
Firstly, in the case of country transfer risk,
where a bank may assign different borrower grades
depending on whether the facility is denominated in
local or foreign currency.
Secondly, when the
treatment of associated guarantees to a facility may be
reflected in an adjusted borrower grade. In either
case, separate exposures may result in multiple grades
for the same borrower.
A bank must articulate in its
credit policy the relationship between borrower
grades in terms of the level of risk each grade implies.
Perceived and measured risk must increase as credit
quality declines from one grade to the next.
The policy
must articulate the risk of each grade in terms of
both a description of the probability of default
risk typical for borrowers assigned the grade and the
criteria used to distinguish that level of credit
risk.
398. The second dimension must reflect
transaction-specific factors, such as
collateral, seniority, product type, etc.
For
foundation IRB banks, this requirement can be fulfilled
by the existence of a facility dimension, which
reflects both borrower and
transaction-specific factors.
For example, a rating
dimension that reflects EL by incorporating both
borrower strength (PD) and loss severity (LGD)
considerations would qualify.
Likewise a rating
system that exclusively reflects LGD would qualify.
Where a rating dimension reflects EL and does not
separately quantify LGD, the supervisory estimates of
LGD must be used.
399. For banks using the advanced
approach, facility ratings must reflect
exclusively LGD.
These ratings can reflect any and
all factors that can influence LGD including, but
not limited to, the type of collateral, product,
industry, and purpose.
Borrower characteristics
may be included as LGD rating criteria only to the
extent they are predictive of LGD.
Banks may alter
the factors that influence facility grades across
segments of the portfolio as long as they can satisfy
their supervisor that it improves the relevance and
precision of their estimates.
400. Banks using the
supervisory slotting criteria for the SL sub-class are
exempt from this two-dimensional requirement for
these exposures. Given the interdependence
between borrower/transaction characteristics in SL,
banks may satisfy the requirements under this heading
through a single rating dimension that reflects EL by
incorporating both borrower strength (PD) and
loss severity (LGD) considerations.
This exemption does
not apply to banks using either the general corporate
foundation or advanced approach for the SL
subclass. Standards for retail exposures
401.
Rating systems for retail exposures must be oriented to
both borrower and transaction risk, and must capture
all relevant borrower and transaction
characteristics.
Banks must assign each exposure that
falls within the definition of retail for IRB
purposes into a particular pool. Banks must
demonstrate that this process provides for a
meaningful differentiation of risk, provides for a
grouping of sufficiently homogenous exposures, and allows for accurate and consistent estimation of
loss characteristics at pool level.
402. For each
pool, banks must estimate PD, LGD, and EAD. Multiple
pools may share identical PD, LGD and EAD estimates.
At a minimum, banks should consider the
following risk drivers when assigning exposures to a
pool:
• Borrower risk characteristics (e.g. borrower
type, demographics such as age/occupation);
•
Transaction risk characteristics, including product
and/or collateral types (e.g. loan to value measures,
seasoning, guarantees; and seniority (first vs. second
lien)).
Banks must explicitly address
cross-collateral provisions where present.
•
Delinquency of exposure: Banks are expected to
separately identify exposures that are delinquent and
those that are not.
(ii) Rating
structure
Standards for corporate, sovereign, and
bank exposures
403. A bank must have a meaningful
distribution of exposures across grades with
no excessive concentrations, on both its
borrower-rating and its facility-rating scales.
404.
To meet this objective, a bank must have a minimum of
seven borrower grades for non-defaulted borrowers and
one for those that have defaulted.
Banks with lending
activities focused on a particular market segment may
satisfy this requirement with the minimum number of
grades; supervisors may require banks, which lend to
borrowers of diverse credit quality, to have a
greater number of borrower grades.
405. A borrower
grade is defined as an assessment of borrower risk on
the basis of a specified and distinct set of rating
criteria, from which estimates of PD are derived.
The
grade definition must include both a description of
the degree of default risk typical for
borrowers assigned the grade and the criteria used to
distinguish that level of credit risk.
Furthermore, “+” or “-” modifiers to alpha or numeric
grades will only qualify as distinct grades if the
bank has developed complete rating descriptions and
criteria for their assignment, and
separately quantifies PDs for these modified
grades.
406. Banks with loan portfolios concentrated
in a particular market segment and range of default
risk must have enough grades within that range to avoid
undue concentrations of borrowers in particular
grades.
Significant concentrations within a single grade
or grades must be supported by convincing empirical
evidence that the grade or grades cover reasonably
narrow PD bands and that the default risk posed by all
borrowers in a grade fall within that band.
407.
There is no specific minimum number of facility grades
for banks using the advanced approach for estimating
LGD. A bank must have a sufficient number of
facility grades to avoid grouping facilities
with widely varying LGDs into a single grade.
The
criteria used to define facility grades must be
grounded in empirical evidence.
408. Banks using the
supervisory slotting criteria for the SL asset classes
must have at least four grades for non-defaulted
borrowers, and one for defaulted borrowers.
The requirements for SL exposures that qualify for
the corporate foundation and advanced approaches are
the same as those for general corporate
exposures.
Standards for retail exposures
409. For
each pool identified, the bank must be able to provide
quantitative measures of loss characteristics (PD,
LGD, and EAD) for that pool.
The level of
differentiation for IRB purposes must ensure that the
number of exposures in a given pool is sufficient so as
to allow for meaningful quantification and validation
of the loss characteristics at the pool level.
There
must be a meaningful distribution of borrowers and
exposures across pools.
A single pool must not
include an undue concentration of the bank’s total
retail exposure.
(iii) Rating criteria
410. A bank
must have specific rating definitions, processes and
criteria for assigning exposures to grades within a
rating system. The rating definitions and criteria must
be both plausible and intuitive and must result in a
meaningful differentiation of risk.
• The grade
descriptions and criteria must be sufficiently detailed
to allow those charged with assigning ratings to
consistently assign the same grade to borrowers or
facilities posing similar risk.
This consistency should
exist across lines of business, departments and
geographic locations.
If rating criteria and
procedures differ for different types of borrowers or
facilities, the bank must monitor for
possible inconsistency, and must alter rating
criteria to improve consistency
when appropriate.
• Written rating definitions
must be clear and detailed enough to allow third parties
to understand the assignment of ratings, such as
internal audit or an equally independent function and
supervisors, to replicate rating assignments and
evaluate the appropriateness of the grade/pool
assignments.
• The criteria must also be consistent
with the bank’s internal lending standards and its
policies for handling troubled borrowers and
facilities.
411. To ensure that banks are
consistently taking into account available information,
they must use all relevant and material information
in assigning ratings to borrowers and
facilities.
Information must be current.
The less
information a bank has, the more conservative must
be its assignments of exposures to borrower and
facility grades or pools.
An external rating can be
the primary factor determining an internal rating
assignment; however, the bank must ensure that it
considers other relevant information.
SL product
lines within the corporate asset class
412. Banks
using the supervisory slotting criteria for SL exposures
must assign exposures to their internal rating grades
based on their own criteria, systems and
processes, subject to compliance with the requisite
minimum requirements.
Banks must then map
these internal rating grades into the five
supervisory rating categories.
Tables 1 to 4 in Annex
6 provide, for each sub-class of SL exposures, the
general assessment factors and characteristics
exhibited by the exposures that fall under each of the
supervisory categories.
Each lending activity has a
unique table describing the assessment factors
and characteristics.
413. The Committee
recognises that the criteria that banks use to assign
exposures to internal grades will not perfectly align
with criteria that define the supervisory
categories;
however, banks must demonstrate that
their mapping process has resulted in an alignment of
grades which is consistent with the preponderance of the
characteristics in the respective supervisory
category.
Banks should take special care to ensure that
any overrides of their internal criteria do not
render the mapping process ineffective.
(iv) Rating
assignment horizon
414. Although the time horizon
used in PD estimation is one year (as described
in paragraph 447), banks are expected to use a longer
time horizon in assigning ratings.
415. A borrower
rating must represent the bank’s assessment of the
borrower’s ability and willingness to contractually
perform despite adverse economic conditions or
the occurrence of unexpected events.
For example, a
bank may base rating assignments on specific,
appropriate stress scenarios.
Alternatively, a bank may
take into account borrower characteristics that are
reflective of the borrower’s vulnerability to adverse
economic conditions or unexpected events, without
explicitly specifying a stress scenario.
The range
of economic conditions that are considered when
making assessments must be consistent with current
conditions and those that are likely to occur over a
business cycle within the respective
industry/geographic region.
416. Given the
difficulties in forecasting future events and the
influence they will have on a particular borrower’s
financial condition, a bank must take a conservative
view of projected information.
Furthermore, where
limited data are available, a bank must adopt a
conservative bias to its analysis.
(v) Use of
models
417. The requirements in this section apply to
statistical models and other mechanical methods used
to assign borrower or facility ratings or in estimation
of PDs, LGDs, or EADs.
Credit scoring models and
other mechanical rating procedures generally use only a
subset of available information. Although mechanical
rating procedures may sometimes avoid some of the
idiosyncratic errors made by rating systems in which
human judgement plays a large role, mechanical use of
limited information also is a source of rating errors.
Credit scoring models and other mechanical procedures
are permissible as the primary or partial basis
of rating assignments, and may play a role in the
estimation of loss characteristics.
Sufficient human
judgement and human oversight is necessary to ensure
that all relevant and material information, including
that which is outside the scope of the model, is also
taken into consideration, and that the model is used
appropriately.
• The burden is on the bank to satisfy
its supervisor that a model or procedure has good
predictive power and that regulatory capital
requirements will not be distorted as a result of its
use.
The variables that are input to the model must form
a reasonable set of predictors.
The model must be
accurate on average across the range of borrowers or
facilities to which the bank is exposed and there must
be no known material biases.
• The bank must have
in place a process for vetting data inputs into a
statistical default or loss prediction model which
includes an assessment of the accuracy, completeness
and appropriateness of the data specific to the
assignment of an approved rating.
• The bank must
demonstrate that the data used to build the model are
representative of the population of the bank’s actual
borrowers or facilities.
• When combining model
results with human judgement, the judgement must
take into account all relevant and material
information not considered by the model.
The bank
must have written guidance describing how human
judgement and model results are to be combined.
•
The bank must have procedures for human review of
model-based rating assignments.
Such procedures
should focus on finding and limiting
errors associated with known model weaknesses and
must also include credible ongoing efforts to improve
the model’s performance.
• The bank must have a
regular cycle of model validation that includes
monitoring of model performance and stability; review
of model relationships; and testing of model outputs
against outcomes.
(vi) Documentation of rating system
design
418. Banks must document in writing their
rating systems’ design and operational details.
The
documentation must evidence banks’ compliance with the
minimum standards, and must address topics such as
portfolio differentiation, rating criteria,
responsibilities of parties that rate borrowers and
facilities, definition of what constitutes a rating
exception, parties that have authority to approve
exceptions, frequency of rating reviews, and
management oversight of the rating process.
A bank
must document the rationale for its choice of
internal rating criteria and must be able to provide
analyses demonstrating that rating criteria
and procedures are likely to result in ratings that
meaningfully differentiate risk.
Rating criteria and
procedures must be periodically reviewed to determine
whether they remain fully applicable to the current
portfolio and to external conditions.
In addition, a
bank must document a history of major changes in the
risk rating process, and such documentation must
support identification of changes made to the risk
rating process subsequent to the last supervisory
review.
The organisation of rating assignment, including
the internal control structure, must also be
documented.
419. Banks must document the specific
definitions of default and loss used internally
and demonstrate consistency with the reference
definitions set out in paragraphs 452 to 460.
420. If
the bank employs statistical models in the rating
process, the bank must document their methodologies.
This material must:
• Provide a detailed outline of
the theory, assumptions and/or mathematical
and empirical basis of the assignment of estimates to
grades, individual obligors, exposures, or pools, and
the data source(s) used to estimate the model;
•
Establish a rigorous statistical process (including
out-of-time and out-of-sample performance tests) for
validating the model; and
• Indicate any
circumstances under which the model does not work
effectively.
421. Use of a model obtained from a
third-party vendor that claims proprietary
technology is not a justification for exemption from
documentation or any other of the requirements
for internal rating systems.
The burden is on the
model’s vendor and the bank to
satisfy supervisors.
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